Memo
To:
Brice Zeller
From: James Peck, P.E.
Date:
May 20, 2010
Re:
South Yuma County Landfill - Contaminated Soil Acceptance Criteria
This memorandum is provided to summarize South Yuma County Landfill’s (SYCL’s) waste
acceptance criteria for accepting petroleum contaminated soil (PCS),
Regulatory Requirements
Contaminated waste soil is generally treated as solid waste in Arizona, subject to federal hazardous
waste listing and characterization criteria. Arizona treats non-hazardous waste soils that are
contaminated with petroleum products in three separate categories, special waste PCS, solid waste
PCS, and non-regulated soils. Special waste PCS is contaminated soil which contains certain
chlorinated aromatic (BTEX) or polynuclear aromatic hydrocarbon (PAH) contaminants at levels
above non-residential soil remediation levels. Special waste PCS must be disposed of at a disposal
facility authorized by the Arizona Department of Environmental Quality (ADEQ) to accept special
waste PCS. Solid waste PCS is contaminated soil which contains BTEX and PAH contaminants at
concentrations between the residential and non-residential soil remediation levels. Solid waste PCS
can be disposed of as solid waste at any facility authorized to dispose of solid waste. Non-regulated
soil is soil that contains BTEX and PAH compounds below the residential soil remediation levels.
Non-regulated soil is not regulated as a solid waste but is considered an inert material.
Table 1 lists the appropriate levels of BTEX and PAH compounds in soils for establishing whether or
not a soil is special waste PCS, solid waste PCS, or non-regulated soil.
South Yuma County Landfill Permits
The SYCL is a municipal solid waste disposal facility operating under an approved Solid Waste
Facility Plan, ADEQ approval No. 50366100.02, as amended January 15, 2010. The SYCL is
approved to accept special waste PCS, and is therefore approved to accept all manner of nonhazardous soils contaminated with petroleum products. The ADEQ approved SYCL as a special
waste facility for accepting special waste PCS in April 2001 (Approval 302233), which is maintained
under SYCL’s solid waste facility plan approval. The Solid Waste Facility Plan includes provisions
for the acceptance and disposal of special waste PCS and solid waste PCS. The ADEQ solid waste
facility plan approval specifically lists special waste PCS as an acceptable waste type at the SYCL.
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Waste Acceptance Criteria
SYCL requires all generators of environmentally contaminated soil to submit a waste profile
identifying the source of the contamination and provide relevant analytical data characterizing the
waste consistent with an approved sampling plan or where appropriate, through generator knowledge
in light of known or potential sources of contamination. Contaminated soil that has the potential to
leach contaminants in excess of toxicity characteristic criteria are required to provide Toxicity
Characteristic Leaching Procedure (TCLP) data on the waste as listed in Table 2. TCLP will be
required for PCS soil with potential to leach lead in excess of 100 mg/L. Contaminated soil that
classifies as either a listed or characteristic hazardous waste under U.S. EPA hazardous waste
classification criteria is not accepted at the SYCL.
Special waste PCS must be accompanied by a special waste manifest including a special waste
generator identification number provided by ADEQ. Generators of special waste PCS must submit a
sampling plan along with analytical test results from an Arizona Department of Health Services
licensed laboratory. Sampling of the special waste PCS must be performed in accordance with the
written sampling plan, which must be developed in accordance with the requirements of EPA’s SW846 or ADEQ’s Quality Assurance Project Plan.1 The sampling frequency for waste characterization
must be consistent with the approved sampling plan. Analytical sampling data must include
polynuclear aromatic hydrocarbons, petroleum aromatics. Other analyses such as soil pH, flashpoint,
and total metals may be requested by SYCL depending on the waste generator’s profile. An
acceptable sampling frequency for PCS soil characterization is as follows:
1-10 cubic yards
11-20 cubic yards
21-100 cubic yards
101-500 cubic yards:
500-10,000 cubic yards:
>10,000 cubic yards:
2, one from each half
3, one from each third
4, one from each quarter
1 per 25 cubic yards, maximum of 10 samples
10 samples plus 1 sample for every 500 cubic yards
above 500 cubic yards
20 samples plus 1 sample for every 5,000 cubic yards
above 10,000 cubic yards
For solid waste PCS, SYCL requires documentation from the generator verifying that the waste is not
hazardous and does not contain any contaminants above the threshold for special waste PCS.
Demonstration that the waste is non-hazardous must be provided by the generator and may include a
determination of soil pH, soil flashpoint, and toxicity either by the TCLP or by total concentrations of
BTEX and metals at levels that could not possibly exceed TCLP thresholds for hazardous waste.
Attachments:
Tables (2)
U.S. EPA, Test Methods for Evaluating Solid Waste, SW-846, 3rd Edition, Volume II: Field Manual, Physical/Chemical
Method, Chapter 9, Revision 6, 2007, and ADEQ, Quality Assurance Project Plan, Chapter 9, May 1991.
1
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TABLES
TABLE 1
Petroleum Contaminated Soil Classification Thresholds
Special Waste
Constituents
(A.R.S. § 49-851A.3
BTEX
EPA Method
8260 or 8021
PAHS
Polynuclear
Aromatic
Hydrocarbons
Commonly found in
diesel and lubricant oil
EPA Method 8310
Regulated
Contaminants
Solid Waste PCS
>Residential SRLs
(in ppm, mg/kg)
Special Waste PCS
>Non-Residential SRLs
(in ppm, mg/kg)
Benzene
0.65
1.4
Toluene
650
650
Ethylbenzene
400
400
Total Xylenes
270
420
Acenaphthylene
3,700
29,000
Anthracene
22,000
240,000
Benz[A]anthracene
6.9
21
Benzo[A]pyrene
0.69
2.1
Benzo[B]fluoranthene
6.9
21
Benzo[K]fluoranthene
69
210
Cyrysene
680
2,000
Dibenz[A,H]anthracene
0.69
2.1
Fluoranthene
2,300
22,000
Fluorene
2,700
26,000
Indenopyrene
6.9
21
Naphthalene
56
190
Pyrene
2,300
29,000
Notes:
ppm = parts per million
mg/kg = milligrams per kilogram
Derived from ADEQ, Petroleum Contaminated Soil Fact Sheet, July 2008, Publication FS 08-14.
TCLP limit
(mg/L)
Waste Limit - Totals
(mg/kg)
Arsenic
5.0
100
Barium
Constituent
100.0
2000
Benzene
0.5
10
Cadmium
1.0
20
Carbon Tetrachloride
0.5
10
0.03
0.6
100.0
2000
Chloroform
6.0
120
Chromium
5.0
100
Cresol
200.0
4000
o-Cresol
200.0
4000
m-Cresol
200.0
4000
p-Cresol
200.0
4000
10.0
200
1,4-Dichlorobenzene
7.5
150
1,2-Dichloroethane
0.5
10
1,1-Dichloroethene
0.7
14
2,4-Dinitrotoluene
0.1
2
Chlordane
Chlorobenzene
2,4-D
Endrin
0.02
0.4
0.008
0.16
Hexachlorobenzene
0.1
2
Hexachloro-1,3-butadiene
0.5
10
Hexachlorothane
3.0
60
Lead
5.0
100
Lindane
0.4
8
Heptachlor (and its epoxide)
Mercury
0.2
4
10.0
200
200.0
4000
2.0
40
100.0
2000
Pyridine
5.0
100
Selenium
1.0
20
Silver
5.0
100
Tetrachloroethene
0.7
14
Toxaphene
0.5
10
Trichloroethene
0.5
10
2,3,5-Trichlorophenol
400.0
8000
2,4,6-Trichlorophenol
2.0
40
2,4,5-TP
1.0
20
Vinyl Chloride
Notes:
mg/L = milligrams per Liter
mg/kg = milligrams per kilogram
0.2
4
Methoxychlor
Methyl Ethyl Ketone
Nitrobenzene
Pentachlorophenol